TP- Comparability of High End Cos with Low End Cos in ITES/ BPO Sector

Vodafone India Services P. Ltd. Vs. DCIT (ITAT Mumbai), ITA No.7140 /Mum/2012, Date of Pronouncement: 26/4/2013

The dispute is regarding selection of comparables for bench marking the international transaction entered into by the assessee. The assessee had selected 9 comparables as unrelated parties for comparing the transaction in case of the assessee. The AO further selected 23 more comparables out of which 2 comparables i.e. Spanco and Flextronics (Seg.) were accepted by the assessee as comparable and the 2

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